companion planning guide to ercb directive 071

7/30/2019 Companion Planning Guide to ERCB Directive 071

1/103

GUIDE

Companion Planning Guide toERCB Directive 071

July 2008

2008-0001


2/103

2100, 350 7Avenue S.W.Calgary, AlbertaCanada T2P 3N9Tel (403) 267-1100Fax (403) 261-4622

403, 235 Water StreetSt. Johns, Newfoundland and LabradorCanada A1C 1B6Tel (709) 724-4200Fax (709) 724-4225

www.capp.ca [email protected]

The Canadian Association of Petroleum Producers (CAPP) represents 130 companiesthat explore for, develop and produce natural gas, natural gas liquids, crude oil, oilsands, and elemental sulphur throughout Canada. CAPP member companies produce

more than 95 per cent of Canadas natural gas and crude oil. CAPP also has 150associate members that provide a wide range of services that support the upstreamcrude oil and natural gas industry. Together, these members and associate members arean important part of a $120-billion-a-year national industry that affects the livelihoodsof more than half a million Canadians.

Disclaimer

This publication was prepared by the Canadian Association of Petroleum Producers (CAPP).

While it is believed that the information contained herein is reliable under the conditions andsubject to the limitations set out, CAPP does not guarantee its accuracy. In addition, CAPP willnot be liable for any liabilities, damages, claims or losses of any nature resulting from the use ofthe information within this document, including the table provided by Jacques Whitford(Appendix 10). The use of this report or any information contained will be at the users sole risk,regardless of any fault or negligence of CAPP or its co-funders.

Any modification and/or publication in either form or content of Jacques Whitfords workproduct, including but not limited to Jacques Whitfords report The Effects of HVP SystemParameters on Dispersion and Thermal Radiation Hazard Extents, is at the sole risk of the HVPWorking Group and CAPP. Jacques Whitford will not be liable to the HVP Working Group andCAPP for any liabilities, damages, claims or losses of any nature resulting from or related to themodification or publication of Jacques Whitfords work product, including but not limited toJacquess Whitfords. The HVP working Group and CAPP agree to indemnify, defend and holdharmless Jacques Whitford for any liabilities, damages, claims or losses resulting from themodification or publication of Jacques Whitfords work product including but not limited toJacques Whitfords report The Effects of HVP System Parameters on Dispersion and Thermal

Radiation Hazard Extents.


3/103

July 2008 CAPP Companion Planning Guide to ERCBDirective 071 i

Overview

This guide is to be used as a companion document to the Energy ResourcesConservation Board (ERCB)Directive 071: Emergency Preparedness and ResponseRequirements for the Petroleum Industry.

WhileDirective 071 contains regulatory information, CAPP has provided this guide toadd more detail, examples, and best practices that will assist in clarifying theregulations. The ERCB regulatory intent and review instructions for ERCB staff toreview ERP applications is also included at the end of the sections in Part A of thisGuide to assist your company in submitting the appropriate information in youremergency response plan (ERP).

DISCLAIMER: This guide is intended only to enhance the understanding ofDirective 071. The ERCB regulations apply in all circumstances.


4/103

July 2008 CAPP Companion Planning Guide to ERCBDirective 071 ii

Contents

Project Scope ..........................................................................................................................1Goal ....................................................................................................................................1

Key Objective .................................................................................................................................1General Approach...........................................................................................................................1How to Use this Guide ...................................................................................................................1

CAPP Companion Planning Guide

1 Introduction1.1 Licensee Responsibility ........................................................................................................31.2 Requirements, Enforcement, and Expectations...................................................................41.3 Purpose of Emergency Preparedness and Response ...........................................................51.4 Whats New inDirective 071 ...............................................................................................5

1.5 Directive 071 Requirements .................................................................................................61.6 ERP Application Process for ERCB Approval ..................................................................6ERCB Intent and Review Instructions for Section 1 ...................................................................7

Part A: Planning Requirements forDirective 071

2 Corporate-level ERPs2.1 Corporate-level ERP Requirements ...................................................................................10

2.1.1 Assessment Matrix for Classifying Incidents .......................................................102.1.2 Communications Planning ......................................................................................152.1.3 Responsibilities of Personnel ..................................................................................16

2.1.4 Incident Management Systems.............172.1.5 Reception Centre...................................17

3 Emergency Planning and Response Zones3.1 Emergency Planning Zone .................................................................................................183.2 Calculating EPZs for Hydrogen Sulphide .........................................................................19

3.2.1 Sour Gas Wells.........................................................................................................193.2.2 Sour Oil Wells, Sour Water Disposal Wells and Sour Observation Wells ..........213.2.3 Sour Gas Pipelines ...................................................................................................213.2.4 Sour Liquid Pipelines ..............................................................................................223.2.5 Facilities .................................................................................................................22

3.3 Calculating EPZs for HVP Product....................................................................................233.3.1 HVP Product Release Rates - Pipelines .................................................................233.3.2 HVP Product Release Rates - Cavern Storage Facility .........................................243.3.3 Gas Composition......................................................................................................243.3.4 Depressurization to Atmospheric Pressure.............................................................243.3.5 Release Orientation ..................................................................................................243.3.6 Release Duration ......................................................................................................25


5/103

July 2008 CAPP Companion Planning Guide to ERCBDirective 071 iii

3.3.7 Dispersion Modelling ..............................................................................................253.3.8 Meteorological Conditions ......................................................................................253.3.9 Averaging Times......................................................................................................253.3.10 Emergency Planning Zone Endpoints ....................................................................25

3.4 Emergency Awareness Zone .............................................................................................26

3.4.1 EAZ for an H2S Release ..........................................................................................263.4.2 EAZ for an HVP Product Release ..........................................................................263.5 Initial Isolation Zone ..........................................................................................................26ERCB Intent and Review Instructions for Section 3 .........................................................27

4 Public and Local Authority Involvement in Emergency Preparedness and Response

4.1 When Are Notification and Consultation Required? .......................................................294.2 Preparing for the Public Involvement Program ................................................................294.3 Conducting the Public Involvement Program ...................................................................31

4.3.1 Public Information Package ......................................................................................324.4 Information Required from the Public Involvement Program...........................................34

ERCB Intent and Review Instructions for Section 4..................................................................34

5 Common Requirements for Site-specific ERPs5.1 Assessment Matrix for Classifying Incidents ...................................................................385.2 Public Protection Measures ................................................................................................38

5.2.1 Notification Within the EPZ ...................................................................................385.2.2 Evacuation and/or Sheltering Within the EPZ.......................................................385.2.3 Notification and Evacuation Outside the EPZ .......................................................395.2.4 Ignition Criteria........................................................................................................40

5.2.4.1 Sour Well Releases.....................................................................................405.2.4.2 HVP Product Releases from a Pipeline or Cavern Storage Facility .......40

5.2.5 Isolation Procedures.................................................................................................415.2.6 Air Quality Monitoring............................................................................................41

5.3 Maps ............................................................................................................415.4 Equipment List ...................................................................................................................425.5 Mutual Aid Understandings ................................................................................................425.6 Telephone Lists....................................................................................................................445.7 Plan Distribution..................................................................................................................455.8 Communications Planning ..................................................................................................465.9 Responsibilities of Personnel .....................................................................................465.10 Incident Management Systems...................................................................................465.11 Record Keeping...........................................................................................................485.12 Reception Centre.........................................................................................................485.13 Downgrading and Stand-down of Emergency Levels ..............................................48ERCB Intent and Review Instructions for Section 5 ........................................................48

6 Sour Well Site-Specific Drilling and/or Completion ERPs 6.1 ERP Submission Requirements..........................................................................................516.2 ERP Content Requirements................................................................................................52


6/103

July 2008 CAPP Companion Planning Guide to ERCBDirective 071 iv

6.3 Critical Sour Well Approval ...............................................................................................536.4 Noncritical Sour Well Approval.........................................................................................536.5 Additional Conditions to ERP Approval ...........................................................................536.6 ERPs for Temporary Surface Pipelines .............................................................................546.7 ERPs for Multiwell Programs.............................................................................................54

6.8 Sour Underbalanced Drilling Operations...........................................................................54ERCB Intent and Review Instructions for Section 6 .........................................................54

7 Sour Operations ERPs7.1 ERP Submission Requirements..........................................................................................567.2 ERP Content Requirements ................................................................................................587.3 Supplements and Updates/Amendments ...........................................................................58

7.3.1 Use of Supplements for Drilling and/or Completion Operations .........................587.3.2 Use of Supplements for Sour Well Workovers, Well Servicing, and Testing.....597.3.3 Supplement Distribution..........................................................................................59ERCB Intent andReview Instructions for Section 7.................................................60

8 ERPs for HVP Pipelines8.1 ERP Submission Requirements...........................................................................................618.2 ERP Content Requirements .................................................................................................618.3 ERP Supplement...................................................................................................................61

8.3.1 Newly Added Pipeline Tie-ins, Facilities, and Operating Areas ..........................618.3.2 Currently Operating System....................................................................................618.3.3 Supplement Distribution..........................................................................................62

ERCB Intent and Review Instructions for Sections 8 and 9....................................................62

9 ERPs for Cavern Storage Facilities Storing HVP Product

9.1 ERP Submission Requirements..........................................................................................649.2 ERP Content Requirements ................................................................................................649.3 ERP Supplement..................................................................................................................64

9.3.1 Newly Added Well, Pipelines, and Facilities..........................................................649.3.2 Supplement Distribution ..........................................................................................65

10 Spill Cooperative Response Plans10.1 Requirements.......................................................................................................................6610.2 Member of an Oil Spill Cooperative ..................................................................................66

10.2.1 Spill Cooperative Response Plan Contents..........................................................6610.3 Nonmember of an Oil Spill Cooperative ...........................................................................66

10.3.1 Spill Response Plan Contents ..............................................................................6710.3.2 Spill Response Equipment Requirements ...........................................................67

ERCB Intent and Review Instructions for Section10..............................................................67


7/103

July 2008 CAPP Companion Planning Guide to ERCBDirective 071 v

Part B - Response Requirements forDirective 071

11 Corporate-level ERPs11.1 Requirements .....................................................................................................................69

11.1.1 Assessment Matrix for Classifying Incidents ......................................................69

11.1.2 Communications Planning ...................................................................................6911.1.2.1 Downgrading and Stand-down of Emergency Levels ........................7011.1.3 Incident Management Systems ............................................................................70

12 Emergency Planning and Response Zones12.1 Emergency Planning Zone ................................................................................................7112.2 Emergency Awareness Zone ............................................................................................7112.3 Response Zones..................................................................................................................71

12.3.1 Initial Isolation Zone .............................................................................................7212.3.2 Protective Action Zone..........................................................................................72

13 Public and Local Government Involvement in Emergency Preparedness and Response 13.1 When are Notification and Consultation Required? ........................................................7413.2 Public Awareness Program ................................................................................................74

14 Common Requirements for Site-specific ERPs14.1 ERP Location...................................................................................................................7614.2 Assessment Matrix for Classifying Incidents ...................................................................7614.3 Public Protection Measures ................................................................................................76

14.3.1 Notification During an Accidental Release..........................................................7614.3.2 Evacuation and/or Sheltering Indoors ..................................................................7814.3.3 Public Protection Measures for an H2S Release ..................................................7814.3.4 Public Protection Measures for an HVP Product Release...................................7814.3.5 Notification and Evacuation Outside the EPZ.....................................................7914.3.6 Ignition Criteria ......................................................................................................79

14.3.6.1 Sour Well Releases ................................................................................7914.3.6.2 HVP Product Releases from a Pipeline or Cavern Storage Facility ...80

14.3.7 Isolation Procedures...............................................................................................8114.3.8 Air Quality Monitoring..........................................................................................81

14.3.8.1 Sour Gas Release from a Manned Operation .......................................8214.3.8.2 Sour Gas Release from an Unmanned Operation ................................8214.3.8.3 HVP Product Release.............................................................................82

14.4 Equipment Location and Calibration ................................................................................8214.5 Communications Planning .................................................................................................83

14.5.1 Downgrading and Stand-down of Emergency Levels........................................8314.6 Plan Maintenance.......................................................................................................8314.7 Incident Management Systems .................................................................................8414.8 Reception Centre........................................................................................................8414.9 Training Sessions ...........................................................................................................8414.10 Exercise Requirements ..............................................................................................85


8/103

July 2008 CAPP Companion Planning Guide to ERCBDirective 071 vi

14.11 Record Keeping..........................................................................................................8514.12 Sale of Property..............................................................................................................8614.13 Overlapping EPZs ......................................................................................................8614.13 Presour and Critical Sour Requirements ..................................................................86

15 Sour Well Site-specific Drilling and/or Completion ERPs 15.1 Presour and Critical Sour Meeting Requirements............................................................8715.2 Equipment Requirements for Critical Sour Well Operations ...........................................88

15.2.1 Conducting Operations..........................................................................................8815.2.2 Release of Equipment ...........................................................................................88

16 Spill Cooperative Response Plan16.1 Member of an Oil Spill Cooperative ..................................................................................89

16.1.1 Spill Training Exercises and Notification Requirements....................................8916.1.2 Training Exercise Report Summaries...................................................................89

16.2 Nonmember of an Oil Spill Cooperative ...........................................................................8916.2.1 Spill Training Exercise and Notification Requirements.....................................8916.2.2 Training Exercise Report Summaries..................................................................89

17 Frequently Asked Questions on the ERCB Implementation Strategy ............................90

Appendices1 Definitions for the Purposes ofDirective 071 ............................................................................932 ERP Approval Application ..........................................................................................................933 Information that Industry Provides to the Public in the EPZ Regarding Exposure to

Hydrogen Sulphide ......................................................................................................................934 Assessment Matrix for Classifying Incidents .............................................................................935 Distribution of an Approved ERP................................................................................................936 Evacuation Requirements.............................................................................................................937 Assessment and Ignition Criteria Flowchart ...............................................................................938 Information Disseminated to the Public at the Onset of and During an Incident.....................939 First Call Communication Form ........................... ........................... ........................... ................. 9310 HVP Pipeline Emergency Planning Zone Tables ........................... ........................... ................. 94


9/103

July 2008 CAPP Companion Planning Guide to ERCBDirective 071 1

Project Scope

ERPs are a legal requirement for many aspects of oil and gas exploration, production,processing, and transportation operations; however, the value of emergency response

preparedness goes beyond regulatory compliance. ERPs help upstream petroleumindustry operators

identify and quantify the risks associated with their operations,

identify strategies to minimize and/or eliminate risks before they contribute toincidents, and

manage the residual risks so that any incidents that occur have minimal impact.

The outcomes of effective preparedness and response can strengthen industryinfrastructure and lessen any potential negative impacts (human, environmental andfinancial) on its operations.

The CAPP Companion Planning Guide to Directive 071 (the Guide) was created to helpcompanies in the Alberta petroleum industry protect employees, the public and theenvironment, as well as meet regulatory requirements in developing, implementing, andreporting emergency preparedness and response activities. The guide should also helpmeet the requirements of other provinces. This document also offers additionalguidance specific to sour gas releases, high vapour pressure (HVP) product releases andspills of hydrocarbons and produced water.

Goal

The goal of this Guide is to answer industry questions from producer membersregarding implementation of the new and pre-existing aspects of ERCBDirective 071

and to provide a location where non-regulatory aspects ofDirective 071 (i.e.,expectations) could eventually be housed.

Key Objective

The key objective of the Guide is to assist the petroleum industry in understanding theERCB regulatory requirements and expectations for developing an ERP and inresponding to an incident.

General Approach

Each section of the Guide mirrors the corresponding section inDirective 071 for ease ofreading and provides implementation guidance and advice on the interpretation of

Directive 071 as well as answers to frequently asked questions. An additional sectionon frequently asked questions (FAQs) regarding the ERCB implementation strategy isincluded as Section 17.

How to Use this Guide

Use this document in conjunction withDirective 071 as a tool to provide in depthclarification and interpretation of the ERCB regulatory requirements. The Guide can


10/103


provide you with more detail, examples, and best practices to clarify the regulations andexpectations set out in the Directive.

The sections, headings, and subheadings of this document are identical to those foundinDirective 071. The Guide also contains additional subheadings in some areas tocover specific topics not addressed in the Directive.

If CAPP has no additional information to enhance a particular section inDirective 071,the corresponding section in the Guide will state that no additional information isoffered or applicable. If there are any FAQs relevant to a topic, they are included at theend of each section, in italics.

CAPP encourages companies to continue to submit FAQs as the Guide will beperiodically updated. FAQs may be submitted to April Dias([email protected]) or Darrell Hunt ([email protected]).
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


11/103


CAPP Companion Planning Guide

1 Introduction

The ERCB uses this subsection to introduce its three core principles pertaining to itsemergency management system. Directive 071 supports the core principles through thereview of ERPs, testing your companys ability to effectively respond to an incident,and observing industry exercises.

Directive 071 was divided into two parts by the ERCB to differentiate between therequirements for obtaining an approved ERP and the requirements for companies toimplement their plan and respond to an emergency. Your company should be familiarwith both parts ofDirective 071 to understand the ERCB regulatory requirements andto maintain an effective emergency management process.

1. The deletion of the word upstream from the title of Directive 071 is a significant

change, implying that the directive may be applied to the entire petroleum industryincluding refining operations. Please clarify as to where and when the directive

should be applied? Directive 071 applies to any petroleum industry operation that

would normally fall under the jurisdiction of Directive 056: Energy DevelopmentApplications and Schedules. The Directive does not apply to refining operations, which

is considered to be a downstream operation.

1.1 Licensee Responsibility

In order to protect the public and the environment your company should

be proactive in identifying hazards,

have an appropriate ERP for your operations,

ensure that your staff are trained and equipped to effectively react to an emergency,and

practice emergency response through combinations of drills and exercises.

1. Does the ERCB consider an operator and a licensee to be the same? Does theERCB consider a contract operator to have the same responsibilities as a licensee?

No. Under the ERCB Acts and Regulations, the licensee is responsible to ensure that

regulatory requirements are met. If the operator was noncompliant in handling alicensees operations, the licensee would be held accountable for the noncompliance.

2. I have several sour gas wells in a field that are contract operated by a companythat owns most of the gas wells in the field. My gas wells are also tied into their

gathering system. Do I need to develop my own ERP or can these wells be placed

under the other companys ERP?


12/103


The sour gas wells that you own but are contract operated by another company can be

placed in their ERP. The ERP should list the wells that are contract operated alongwith the company that owns the well. Your company should ensure that processes are in

place to notify you during an emergency.

1.2 Requirements, Enforcement, and Expectations

The numbered must statements in Directive 071 represent low and high risk ERCBregulatory requirements that might lead to enforcement actions against your companyfor noncompliance in those areas. The list of enforceable regulatory requirements andtheir risk ranking are found on the ERCB website.

Risking of the must statements was based on a typical non worst case scenario andwas scored by the ERCB on impact to health and safety, environment, conservation,and stakeholder confidence. In general most high risk must statements are those thatcould pose a risk to the safety of residents within the emergency planning zone (EPZ).

Statements inDirective 071 that contain the words should, is expected to, andis encouraged are ERCB expectations that companies will follow a guideline orrecommended practice and are not subject to noncompliance enforcement actions

by the ERCB.

ERCB Bulletin 2008-15 contains the implementation schedule for Directive 071. Keydates for calculating EPZs using ERCBH2S and revising ERPs are as follows.

Commencing April 8, 2008 Companies will need to use Directive 071 andERCBH2S for all new well, pipeline, and facilityERPs and follow the new routine/nonroutineapplication process. Some ERPs will be eligiblefor temporary exemption.

ERPs eligible for temporary

exemption site-specific drilling and completion ERPs

submitted to the ERCB and/or approved priorto April 8, 2008.

Existing sour production facility ERPs thatwere submitted to the ERCB and receivedapproval prior to April 8, 2008.

July 2 to December 31, 2008 Companies will need to recalculate all well and

pipeline EPZs within existing facility ERPs andsubmit the results to the ERCBs EmergencyPlanning and Assessment Section

December 31, 2008 to July 2,2009

The Emergency Planning and Assessment Sectionwill assess the EPZ information submitted andprovide a full implementation plan by July 2,2009, for updating existing facility ERPs.


13/103


1.3 Purpose of Emergency Preparedness and Response

A serious incident is generally followed by a period of confusion and uncertainty whenmajor decisions must be made. If personnel are unprepared, they may be overwhelmedand unable to deal with the emergency adequately. Proper planning and preparation will

help your company activate action plans and mobilize response teams and resources ina safe, effective, and efficient manner, reducing the overall impact of the emergency.

The planning process can also help companies minimize their risks by identifyinghazards and controlling or eliminating them before an incident occurs. A thorough ERPidentifies what types of emergencies might occur, probable scenarios, levels of risk, andprovides information on systems for responding adequately to these emergencies.

An effective ERP is concise and well organized with sufficient detail to ensure quickaccess to critical information. The amount of information is determined by the potentialrisks identified.

Implementing an effective ERP

ensures immediate and effective actions by operating personnel,

emphasizes/encourages coordinating activities between responders and governmentagencies,

protects the public and reduces danger to workers and responders,

minimizes impact on property and the environment, and

maintains effective communication with all parties involved or impacted by theemergency.

The ERCB had originally defined the purpose of an ERP as ensuring a quick, effective

response to emergencies in order to protect the public from fatalities and irreversiblehealth effects. They have expanded the purpose to encompass the broader spectrum ofpublic safety.

1.4 Whats New in Directive 071

Table 1: Summary of New Requirements inDirective 071 outlines the key changes tothe June 2003 version of this Directive. The major changes toDirective 071 aresummarized below

your company can no longer apply for a reduced emergency planning zone (EPZ),

emergency levels are no longer used to determine the need for evacuation orsheltering,

a new ERP application process has been introduced,

companies are required to use the new Assessment Matrix to classify an incident,


14/103


the reduced hydrogen sulphide (H2S) release from using a surface controlledsubsurface safety valve (SCSSV) can be used to calculate the well EPZ,

all companies will be required to use the ERCBH2S model in calculating EPZs forsour wells, pipelines, and facilities,

the 20 ppm (3-minute average) criterion for evacuation has been changed to 10 ppm(3- minute average), and

the requirement for an annual update has been removed from the directive.

There are additional changes in the directive that are listed in Table 1 and minorchanges that have not been captured by this table. Your company is advised to read theentire directive to ensure that you are aware of all the changes.

1.5 Directive 071 Requirements

The ERCB administers the regulatory requirements ofDirective 071 through the Oil

and Gas Conservation Regulations and the Pipeline Regulation.Directive 071 isreferenced throughout those documents. For your information, each section in thisGuide will reference the appropriate ERCB regulation that applies to a specific type ofERP.

The ERCB also states inDirective 071 that it has adopted the most recent edition of theCanadian Standards Association (CSA) standard CAN/CSA Z-731-03EmergencyPreparedness and Response and expects it to be used by the petroleum industry inconjunction withDirective 071 when your company develops its emergencypreparedness and response programs. For the most part material found in the standardhas been expanded on in the directive; however, the Annexes in CSA Z-731 contain

valuable reference material.Companies should be familiar with the content of CSA Z-731; however,Directive 071contains the requirements that need to be followed to satisfy the ERCBs requirements.CSA Z-731-03 may be purchased from the Canadian Standards Association.Instructions on how to obtain the document are found on the CSA Website atwww.csa.ca/standards/.

1.6 ERP Application Process for ERCB Approval

ERP applications and supplements to ERPs will now have to be registered through the

ERCB Digital Data Submission (DDS) system, which is compatible with the currentindustry standard desktop environment. The new ERCB application process wasdesigned to streamline the review process and reduce the waiting time for companies toget approval for ERP applications. The applications process is similar to the facilityapplications process used by the ERCB forDirective 056submissions.


15/103


To submit an ERP application to the ERCB your company will need to provide

a covering letter that sets out what is being asked for,

the application form (found in Appendix 2 ofDirective 071),

a copy of the ERP, and

a copy of the comma separated value (CSV) batch export file from ERCBH2Ssubmitted electronically to the Emergency Planning and Assessment Section [email protected].

1. How do I register my application on the ERCB DDS system? The DDS system maybe accessed through the ERCB Website atwww.ercb.gov.ab.ca. Applications may besubmitted using the ERCBs current DDS protocol, which requires your company to

have an identification code and password to access the system. The ERCB will notify

your company via email of the registration and disposition of an application.

2. Do you send the CSV file in first then courier over your ERP and register it on

DDS or the other way around? The process for submitting an ERP application is the

following

register the ERP through the ERCB DDS system,

send in the CSV batch export file electronically, and

submit the ERP to the Emergency Planning and Assessment Section.

3. Do I need to attach the CSV batch export file to my Directive 056 application? No.Your company will use the ERCBH2S calculation in the Directive 056 application, but

you only need to submit the CSV batch export file electronically to the ERCB

Emergency Planning and Assessment Section to support the ERP application..

4. Is the new application form to be printed and forwarded in written format? Theapplication form should be in written or printed format and submitted with the ERP to

the ERCB Emergency Planning and Assessment Section.

ERCB Intent and Review Instructions for Section 1

The ERCB will review the following when assessing an ERP

ERP plan reference number

Registration date

Application file number

ERP name

Company name

B.A. code (issued to applicant)

Company contact information Name, Telephone, FAX, Email addressConsultant company

B.A. code (issued to consultant)

Consultant contact information) Name, Telephone, FAX, Email address
http://www.ercb.gov.ab.ca/http://www.ercb.gov.ab.ca/http://www.ercb.gov.ab.ca/http://www.ercb.gov.ab.ca/


16/103


Type of ERP Sour well site-specific noncritical - drilling, completions,

servicing/workover, multi well

Sour well site-specific critical - drilling, completions,servicing/workover, multi well

Sour Operations

Supplement

HVP Pipeline

HVP Cavern Storage FacilityAre there any significant deficienciesthat make the ERP technically

incomplete?

Check to see if the applicant failed to appropriately addressand/or explain the selected bold boxes marked on the ERPapplication form.

Check to see if the ERP contains information that is

inconsistent with the information contained within a relatedDirective 056 application/licence.


17/103


Part A: Planning Requirements for Directive 071

Sections 2 - 10


18/103


2 Corporate-level ERPs

2.1 Corporate-level ERP Requirements

In a court of law the accountability and liability for company operations, including lossof life or damage to the environment, rest with a firms senior management anddirectors. Laws require them to have systems in place to protect the public andminimize impacts to property and the environment.

Corporate-level ERPs are used to handle an emergency when your companysoperations do not require aDirective 071 site-specific ERP. They are legal requirementunder the following ERCB Acts and Regulations

Sections 8.002(1) and 8.002(2) ERCB Oil and Gas Conservation Regulations

Sections 50.1(1) and 50.1(2) ERCB Pipeline Regulation

The ERCB regulations may be found on the ERCB Website atwww.ercb.ca/portal/server.pt.

A corporate-level ERP addresses how your company will handle an emergency andincludes

the range and types of hazards and associated emergencies that are applicable toyour operations, and

the level of detail required to address each item depending on the nature of theoperations that the plan covers.

A copy of the corporate-level ERP should be readily available at a response location in

your companys area of operations so that staff can use it to effectively respond to anincident.

Corporate-level plans do not have to be submitted to the ERCB for approval; however,the ERCB may occasionally ask a company to submit the ERP for review. Theminimum amount of information that should be included in a corporate-level ERP isoutlined in the subsections below.

2.1.1 Assessment Matrix for Classifying Incidents

Many companies have developed their own systems for classifying an incident. This

could lead to confusion if a response is required from another company, governmentagency, regional health authority (RHA), or local authority and that party is using adifferent incident classification system. The magnitude of the required response mightnot be appropriate for the level of emergency.


19/103


The assessment matrix for classifying incidents (Appendix 4 -Directive 071) wasdeveloped so that incidents throughout the province could be classified andcommunicated to others on a consistent basis. Your company is required to include theassessment matrix in the corporate-level ERP and all site-specific ERPs and to use it to

classify an incident.

The assessment matrix consists of a series of tables designed to classify an incidentbased on the consequence of the incident and the likelihood of escalation. Table 1 isused to rank the consequence of the incident from minor (1) to catastrophic (4) basedon the following consequences in each category if they are applicable.

What was the impact on workers at the site?

What kind of media interest could the incident attract?

What is the potential impact of any liquid release?

What is the potential impact of any gas release?

The worst case scenario in Table 1 determines the rank of the consequence of theincident.

Table 2 ranks the likelihood of the incident escalating from unlikely (1) to almostcertain or currently occurring (4) based on your companys assessment of how wellthe incident is being controlled and whether outside resources will be required.

Table 1. Consequence of inc identRank Category Consequence in category

1 Minor

No worker injuries. Nil or low media interest.

Liquid release contained on lease. Gas release impact on lease only. No odour from gas detected off site.

2 Moderate

Medical aid treatment required for on lease worker(s) Local and possible regional media interest. Liquid release not contained on lease. Liquid release can be contained off lease.

Gas release impact has potential to extend beyond lease. Odour complaints likely.

3 Major

Worker(s) requires hospitalization.

Regional and national media interest. Liquid release extends beyond lease and is not contained. Gas release impact extends beyond lease with potential to jeopardize public

health/safety.

4 Catastrophic

Fatality. National and international media interest.

Liquid release extends off-lease and is not contained. There is potential for, or therelease is, impacting water or sensitive terrain.

Gas release impact extends beyond lease and public health/safety is jeopardized.


20/103


The sum of the ranking from Table 1 and Table 2 will give your company the risk level,which is then used to assign the incident classification (Table 3).

Thefollowi

n

Table 2. Likelihood of incident escalatingRank Descriptor Description

1Unlikely

The incident is contained or controlled and it is unlikely that the incident will escalate.There is no chance of additional hazards. Ongoing monitoring required.

2Moderate

Control of the incident may have deteriorated but imminent control of the hazard bythe licensee is probable. It is unlikely that the incident will further escalate.

3Likely

Imminent and/or intermittent control of the incident is possible. The licensee has the

capability of using internal and/or external resources to manage and bring the hazardunder control in the near term.

4Almost certain

or currentlyoccurring

The incident is uncontrolled and there is little chance that the licensee will be able tobring the hazard under control in the near term. The licensee will require assistancefrom outside parties to remedy the situation.

What is the likelihood that the incident will escalate, resulting in an increased exposure to public health, safety, or theenvironment?

Table 3. Incident classificationRisk level Assessment results Examples

Very low

2-3Alert

Circulating a kick during drilling; a small spill of avolatile chemical product on site; a small release of sourgas from a leaking valve; a small oil spill from a tank ona single well battery.

Low

4-5Level-1 emergency

A stuffing box on a pumping oil well has cracked and oilis spraying off lease into an adjacent field; severalworkers have been knocked down by sour gas afterentering a metering shack and require hospitalization; aseal on a sour gas wellhead has failed and sour gas could

jeopardize public safety; a rig hand has been severelyinjured by a joint of drill pipe falling off the pipe rack.

Medium

6Level-2 emergency

A fire is burning in a compressor station near a major cityand there is significant regional interest; an oil spill froma well extends beyond the lease and is heading towards asmall creek; an explosion at a battery has hospitalizedseveral workers, but the hazard will shortly be undercontrol.

High

7-8Level-3 emergency

An explosion in a slightly sour gas well ruptures thecasing creating a blowout outside the casing; severalworkers are killed while attempting to bring a sour gaswell under control; an oil pipeline ruptures at a rivercrossing and spills oil several kilometres upstream of thewater intake of a large town; an uncontrolled release ofHVP product from a cavern storage facility near a majorcity catches fire and creates national media interest.


21/103


The following examples illustrate how the assessment matrix should be used.

______________________________________________________________________

Example 1 - Alert

A choke on above ground piping leading off the wellhead of a flowing oil well cracksand begins to spray oil. The quantity of oil spilled amounts to several litres and isconfined to the area immediately adjacent to the well. The operator arrives on site,surveys the damage, and immediately shuts in the well. The choke is replaced and thewell is placed back on production.

The consequence/impact of the spill is established as minor (1) because the release iscontained on site. The likelihood of the incident escalating is unlikely (1) because therelease can immediately be controlled and the choke replaced.

The risk level would be ranked as Very Low (2) [minor (1) + unlikely (1)] and theincident would be classified as an Alert.

______________________________________________________________________

Example 2 - Level 1

While changing out a bottomhole pump on an oil well, one of the rods slips from therack on the monkey boards striking a rig hand on the arm. The rig hand subsequentlyrequires hospitalization. A reporter for a local newspaper arrives on scene and indicatesthat he will run a story in the paper.

The consequence of the incident could be moderate (2) based on local media interest ormajor (3) based on the rig hand requiring hospitalization. Always use the highestcategory/rank which in this case is major (3). The likelihood of the incident escalatingis unlikely (1). The risk level would be ranked as Low (4) [major (3) + unlikely (1)] andthe incident would be classified as a Level 1 emergency.

______________________________________________________________________

Example 3 - Level 2

A farmer is working in his field and accidentally shears off the master valve above thebonnet on the wellhead with his combine. The farmer is not hurt but the well is ventingsweet gas and spraying salt water. The produced water from the spray is pooling on thefarmers land and gas is escaping at about 40 000 m 3/d. It is evident that it will takeseveral days to remove the farmers combine, obtain the necessary equipment, and killthe well to bring it under control. The well is near a major town and the regional press

has picked up the story.The consequence of the incident could be major (3) based on regional media interest orthe liquid release extending beyond the lease site. The likelihood of the incidentescalating is likely (3) which means that imminent control using internal and externalresources is possible. The risk level would be ranked as Medium (6) [major (3) + likely(3)] and the incident would be classified as a Level 2 emergency.


22/103


Example 4 Level 3

During the drilling of a sour gas well, the crew hits a pocket of high pressure gas at ashallow depth. The drill pipe shoots out of the hole and strikes the travelling blockigniting the escaping gas and setting the rig on fire. The rig crew is forced to pull backto safety; however, the driller has been hit by a joint of drill pipe and is seriously

injured. The rig is located next to a major highway and the fire is visible to motoristspassing by. It is clear that because of the location, media interest will be high.

The consequence of the incident could be major (3) based on regional media interest orthe rig hand requiring hospitalization. The likelihood of the incident escalating is almostcertain or currently occurring (4) with little chance that the licensee will be able to bringthe hazard under control in the near term. The risk level would be ranked as High (7)[major (3) + almost certain (4)] and the incident would be classified as a Level 3emergency.

______________________________________________________________________

Companies also have to include Appendix 4 Table 4 - Incident Response in a corporate-

level ERP or site-specific ERP as part of a comprehensive response program for dealingwith an incident. The ERCB requirements are minimum responses that your companyshould initiate as part of the communications, actions, and resource strategies once youhave determined the level of emergency. The table can be submitted as is or yourcompany can expand on it.

Companies that use a different type of assessment matrix can include it in the ERP butit should be linked to the ERCB assessment matrix that has to be included in the ERP sothat the incident response is similar to that of Appendix 4.

1. Do the ERCBs definitions of level of alert and emergencies apply specifically to

sour operations? They apply to any hazard that has the potential to impact the public

or the environment including sour gas, HVP product, and oil and saltwater spills.

2. When you say that the matrix and the response actions at various levels must be

included in the ERP, do you mean verbatim or by intent? The Assessment Matrix wasestablished to provide consistency in classifying incidents in the oil patch and to ensure

that the level was understood by others. The ERCB has indicated that every company is

required to put the Assessment Matrix in the ERP verbatim. The wording for the

incident response doesnt have to be verbatim; however, the communications, actionsand response strategies should be similar to what the ERCB has in Appendix 4.

According to the ERCB, these are the minimum actions that every company is expected

to carry out for each level of emergency.

3. Is an alert an emergency level? An alert is an on-site incident that can be handledthrough normal operating procedures. It is not considered to be an emergency.

4. It is unclear which incidents Appendix 4 Table 4 Incident Response applies to. Is

it only for H2S and HVP product incidents, incidents with off-site impact, or all

incidents including on-site medical emergencies, sweet spills etc. with no off-siteimpact? The Incident Response table contains the minimum actions that a company is


23/103


expected to take for an alert or a level of emergency with respect to communications,

actions and resources and applies to all incidents both on site and off site.

5.Please provide some examples of what types of incidents could be classified as an

alert?Some examples would be

a small leak from a needle valve on a wellhead, circulating out a kick during a drilling operation, or

H2S detectors pick up a sour gas release on the plant lease site causing thecompany to investigate. It turns out to be a substantiated release and not a falsealarm.

2.1.2 Communications Planning

The goal for communications planning is to establish policies and processes for thecoordination of communications within your company and between any applicable

outside stakeholders such as support services, the public, the media, regulatoryagencies, and suppliers in the event of an emergency. Communications planningsupports the ERP and addresses communication response in the EPZ, media relations,and communication issues including procedures for the assessment of potentiallyharmful situations and the methods for responding to these situations quickly andeffectively.

Communications plans establish guidelines for dealing with a variety of situations, andensures that your companys staff and communicators are familiar with thoseprocedures and their roles in the event of an emergency.

The objectives of a communications plan are to

assess the situation, define response strategies, and determine whether acommunications response is warranted;

assign communications resources and responsibilities (a communications team thatwill make recommendations on appropriate responses); and

implement immediate action to

- identify those parties that should be informed about the situation,

- communicate facts about the emergency, and

- restore order and/or confidence.

1. My company feels that we just have to be aware of the communications processesthat are there. Why do we need a section in the ERP dealing with a communications

plan?Most companies find it advantageous to actually develop a communications plan

rather than just be aware of the processes that need to be there.

During an emergency it is easy to overlook a procedure or process if the plan is notavailable for reference. Your plan needs to meet the requirements of the Directive 071


24/103


Section 5.8, but it is not necessary to have it in one section as long as the elements arepresent in the plan.

2.1.3 Responsibilities of Personnel

To successfully implement and manage an emergency response operation, specific rolesand responsibilities are needed. Consider these positions/roles when developing aresponse organization. Your company may have a different name for them.

Command

Corporate EOC/crisis manager: person incharge of managing the corporate crisismanagement teamRegional emergency operations centre(REOC)/ emergency manager in charge of

the regional EOCOn Scene/IncidentCommander/Operations Section Chief:person in charge of the on- scenecommand post (OSCP)

Liaison officerInformation officerSafety officerCommunications officer

PlanningPlanning section chiefFinance section chief

Logistics section chiefOperations section chief

OperationsEnvironmental assessment and damagemitigation

Medical assistance andtransportation

Resource procurement/ logistics Reception centre coordinationPublic notification coordination Public safety: to provide overallstrategy to protect the public

Government Interface/Liaison SecurityLegal advice Finance/cost controlAir support

ResponseReconnaissance Search and rescue/evacuationResource staging area Road blocksSpill control Fire response


25/103


2.1.4 Incident Management Systems

Adopting an incident management system that is compatible with your companyscapabilities minimizes the impacts of hazards on public health/safety and property,facilities/operations, the environment, and your companys reputation. The ERCB

would like to see details of your incident management system (i.e., Incident CommandSystem (ICS), Emergency Site Management System, etc.) along with a discussion onthe roles and responsibilities of personnel at the on-site command post, regionalemergency operations centre (EOC), and the corporate EOC.

A single EOC with appropriate representation from the local authority, provincialdepartments/agencies (ERCB, RHAs, Alberta Environment, RCMP, etc.) and theresponsible company can be very effective in handling an emergency. The ERCB is notmandating that operations be handled this way but is encouraging companies toconsider setting up a single EOC with this type of representation during an incident.

2.1.5 Reception Centre

Your company is required to have procedures in the corporate-level ERP for

designating responsibility to locate a suitable reception centre,

activating the reception centre,

contacting the local authority to advise them of the location, and

meeting and registering evacuees.


26/103


3 Emergency Planning and Response Zones

3.1 Emergency Planning Zone

The ERCBH2S model will provide a circular emergency planning zone around a

release of H2S. A computer model simulating an HVP product release will also providea circular zone. Your company is required to modify the shape and extent of the EPZbased on the physical features of the area such as topography, access and egress routes,residences adjacent to the EPZ (within 25 metres), information gathered from the publicinvolvement process (i.e., sensitivities to H2S, special needs, etc.) or any other factorthat may require including residents within the EPZ.

Figure 1 in Directive 071 illustrates the different types of planning and response zonesthat are discussed throughout the directive. The ERCB has introduced the use of theterms IIZ and PAZ to clarify where industry should focus its response during anincident. Your companys response to an incident is basically the same as under the olddirective. Response is required immediately adjacent to and downwind of the release.

1. Can my company still submit an application for a reduced EPZ? Your companycan no longer submit an application to the ERCB for a reduced EPZ. Arguments that

were used for requesting a reduced EPZ have been included in the model. The

ERCBH2S model will have to be used to calculate the size of the EPZ.

2. What will happen to facilities that already have a reduced EPZ? All EPZs will

have to be recalculated using the ERCBH2S model? The ERCB has developed an

implementation schedule for your company to use in resubmitting the sour operatingand site-specific ERPs. The implementation schedule is found in ERCB Bulletin 2008-

15 and was issued in April 2008.

3. Some of the ERCBH2S calculated EPZs are larger than I expected. Is thereanything I can do to affect the size? The biggest contributor to the size of an

ERCBH2S calculated EPZ is time. The faster an H2S release to atmosphere is stopped,

the smaller the EPZ. There are several ways to impact this time. The most commonmethods for wells are ignition or installation of SCSSVs, and for pipelines it is the ESD

valve closure settings. These options, along with others are available in a subsection on

the ERCBH2S inputs page called Source Mitigation.

4. Our company plans to develop a work camp for its oilsands project and the only

development within the project EPZ will be the work camp. Do we need to develop an

ERP? Essentially workers in a camp are considered members of the public when theyare off duty and the place that they stay in is considered to be surface development.

Your company would have to develop an ERP to respond to the area.

5. Our drilling and completions group is not comfortable using a 15-30 minute

ignition time in the model even though the rig crew is on site and they have multiple

methods of ignition because there is the possibility that ignition criteria would not be

met in that short time period. Are we interpreting the ignition time that we use in theERCBH2S model properly?


27/103


When a company is using the ERCBH2S model it should base the ignition time for a

release on

1. How quickly could the release be ignited? If there are staff on site at all times (i.e.,

drilling a well, a servicing operation, etc.), the release could theoretically be ignitedright away. That decision has nothing to do with the Ignition Assessment and Criteria

Flowchart.

2. Keeping the above in mind, you want to make sure that everyone is accounted for

and the ignition team is prepared to ignite before your company proceeds.

For a manned operation the model will let you select a time ranging from 15 minutes to

720 minutes. The EPZ calculated by the model is based on the time that it takes to

ignite after the initial release of sour gas. Fifteen minutes was selected as the minimum

time to muster on-site personnel and send in the ignition team to ignite and is thesmallest number that can be inputted into the model. You should pick a realistic time to

ignite based on company experience from ignition drills. That is the time that you would

use in the model to determine the size of the EPZ.

The decision to ignite a release is based on the criteria in Appendix 7. Once any ofthose conditions have been met, ignition has to occur within 15 minutes after the

decision to ignite. This is not the same as the time selected for input into the model andmay allow your company some time to bring the release under control without igniting,

if the Appendix 7 conditions have not been met.

3.2 Calculating EPZs for Hydrogen Sulphide

3.2.1 Sour Gas Wells

If you are drilling a sour gas well, your company will be required to determine the H 2Srelease rate based on the methodology found inDirective 056. If the well is onproduction and absolute open flow (AOF) rates are not available, the ERCB will allowyour company to use offset data, if available, or a rule-of-thumb calculation based on 3times a wells current production capability.

When you calculate a release rate for an acid gas injection well the worst case releasescenario occurs when the reservoir has been fully repressured. The AOF is determinedor calculated by using the release up the tubing string.

Your company can take credit for the installation of SCSSVs and downhole

chokes in determining the H2S release rates for producing sour gas wells and acid

gas injection wells. This assumes that the SCSSV closes immediately after a pressuredrop at surface and limits the H2S release to the volume in the tubing above the valve.The ERCB will expect that companies provide proper maintenance and testing of theSCSSVs during the wells operational life.

1. My company has purchased several hundred slightly sour producing wells in a

field and we have very little absolute open flow (AOF) data for the wells. Now that wehave to recalculate the EPZs using ERCBH2S, do we have to test all of the wells to


28/103


obtain a flow rate? When you add up the lost production and the cost to test the wells,

its going to cost us a fortune. Cant we use a rule of thumb method to estimate thewellhead AOF? Yes. For producing wells the ERCB will let your company use a rule-

of-thumb calculation for the wellhead AOF based on 3 times a wells current production

capability. Another method also approved by the ERCB would be to use a

representative AOF from another well in the area.2. Can different EPZs be used throughout the drilling operation? No. Worst case

scenarios will have to be used to develop EPZs for an ERP. The ERCB will not acceptERPs with a multi-level EPZ for each sour zone. Should there be an incident while

drilling into one of the sweet zones or a sour zone with a lesser release rate, your

companys response is expected to match the predicted impact; however, as a

minimum, notification will have to include all residents within the worst case EPZ.

3. Can a different EPZ be used for drilling versus completions? Yes. Drilling and

completion rates are usually different and therefore a different size EPZ can be used forthe completion phase. Depending on the zone being completed, the type of completion,

or the determination of a new release rate, the EPZ could be either smaller, larger, or

the same size.

4.If a company determines, after they have consulted the public, that the release rate

is actually higher or lower than what they told the public, what should they do? If the

release rate is higher, the public has to be notified and the ERP revised for the largerEPZ. That would include notification and consultation for members of the public

outside of the existing EPZ. If the release rate is lower, the company will be required to

use that rate with the corresponding EPZ and notify those residents who are now out of

the EPZ.

5. I have some wells with subsurface safety valves that are not surface controlled.

Can I still select this option under Source Mitigation in the ERCBH2S mode? No.

These valves cannot be maintained reliability unless they are surface controlled.

6. In the ERCBH2S model I have selected SCSSV for my well, but the minimum timeunder Time from release until stop flow or ignition still shows 15 minutes. Why?

The phase of well operation selected must be producing/injection in order to receive a

time credit for the valve.

7. For existing wells should you use the highest H2S concentration from any

formation capable of flowing to surface based on a search of data from the area or is

this based on your own well data? When using ERCBH2S for a production scenarioyou would use the highest value from the particular wells production data. When using

the model for drilling and completion scenarios, you will not know the data, so you

would use the highest value from your search of the area.


29/103


3.2.2 Sour Oil Wells, Sour Water Disposal Wells, and Sour ObservationWells

Non flowing sour oil wells and sour water disposal wells on vacuum are normallyincapable of flow back to surface. An ERP will not be required if the well is incapable

of flowing back to surface without mechanical assistance.

A release from flowing sour oil wells, sour water from injection wells under pressure,or sour observation wells, capable of flowing, will pool on surface and sour solution gasdissolved in the fluid will be released as a result of the pressure drop. Sour gas releaseis based on the liquid flow rate to surface and the gas-to-liquid ratio.

1. If a sour oil well is depleted over years and wont flow, is shut-in and physically

disconnected from the pipeline still considered part of the gathering system? No it isnot considered to still be part of the gathering system and because it can no longer flow

to surface without mechanical assistance does not require an ERP. The ERCB requires

that the well be suspended properly so that H2S can no longer reach the surface.

2. My well is only slightly sour (50ppm). Do I have to use the ERCBH2S model tocalculate the EPZ? Wells with an H2S content less than 100 ppm do not have to be

modelled.

3.2.3 Sour Gas Pipelines

Sour gas pipelines and sour multiphase pipelines are handled the same way usingERCBH2S. When dealing with a sour multiphase pipeline it is important to rememberto use the combined composition of the gas and liquids including water when inputtingthe information into ERCBH2S.

1. How does the ERCB expect operators to manage public safety within very large

sour pipeline EPZs? Managing public safety within the EPZ of large sour pipelines isvery much dependent on the type of release and the concentration of H2S. If the pipeline

rupture is a guillotine break then the release is non continuous, assuming the ESDs

close properly. Residents within the area should have been advised during the public

involvement program to shelter indoors upon detecting sour gas. Sheltering-in-place isthe best public protection measurefor a non continuous release if evacuation mightplace residents at risk.

A more common type of pipeline failure is the development of small holes from

corrosion or pipe defects. It may not be large enough to trigger the deployment of the

ESDs and likely is detected through odour complaints. A company will have more timeto deal with public protection measures and will probably have sufficient time toevacuate residents downwind of the release in the PAZ before they come into contact

with H2S.


30/103


2. Why is my pipeline EPZ different using ERCBH2S than it was using the

nomograph? Primarily the changes are driven by the volume and duration of therelease. This, in turn, is impacted by the presence, type, setting, and subsequent

behaviour of pipeline ESD valves. Many of these parameters can be controlled by the

user to reflect actual operating conditions or allow users to investigate changes that

would result in a more appropriate sized EPZ.3. How can I find out what the default settings and data entry ranges are for

ERCBH2S inputs are they listed in Directive 071 or in the ERCBH2S User Guide?The default settings and data entry ranges are only shown on the ERCBH2S inputs

page.

4. In the old method of calculating pipeline EPZs, it was just the licensed amount of

H2S that was used to calculate the release volume but now it has to be the actual. Is

this true? The old method of calculating the pipeline EPZ did require that you use the

licensed amount of H2S and in addition the pipelines licensed pressure. When you useERCBH2S to calculate the pipeline EPZ, your company can use the licensed H2S

concentration or the actual H2S concentration and the licensed pipeline pressure or the

maximum operating pipeline pressure.

3.2.4 Sour Liquid Pipelines

The volume of H2S from a sour liquid pipeline release is treated in the same manner asa gas release from fluid at stock tank conditions.Sour solution gas dissolved in thepooled fluid will be released as a result of the pressure drop. The volume of H 2Sreleased is based on the amount liquid released from the pipeline, the gas-to-liquid ratioand the concentration of H2S.

1. I am modelling something in the Liquid Pipeline or Liquid Well portion of the

ERCBH2S Inputs page. The flow rate is over the allowable limit of 10 000 m3/d. How

can I proceed? ERCBH2S will model liquid flow rates in excess of 10 000m3/d but as

you have noticed there is an orange warning for this input row in column E on theERCBH2S inputs page. Go ahead and submit your calculations to the ERCB with your

other submission materials, but attach a note to the submission indicating that the error

message shown for the ERCBH2S calculation result is related only to the flow rate. The

maximum allowable entry for a liquid flow will be changed in a future version ofERCBH2S.

2. I used ERCBH2S and found that my EAZ actually falls within the EPZ. Did I dosomething wrong?No. There was a glitch in the ERCBH2S model that created this

problem. It has since been corrected.

3.2.5 Facilities

When calculating the EPZ for a sour facility your company should only use the largestEPZ for any single pipeline entering or leaving the facility. Although there may be


31/103


several pipelines within the pipeline right-of-way, the probability of more than one linerupturing at the same time and same location is remote.

1. At what point in the lease should I measure the EPZ from? EPZ measurements for

a facility lease are taken at the facility lease boundary.

3.3 Calculating EPZs for HVP Product

There is no specific method currently defined by the ERCB for calculating an EPZ forHigh Vapour Pressure (HVP) production facilities. The ERCB encourages companies touse the table found in Appendix 101 in this document or to use an appropriate dispersionmodel. The requirements set out below provide the minimum standards that are appliedwhen undertaking a hazard assessment for HVP product to determine the EPZ.

Hazard analysis is a complex task requiring an understanding of source conditions, fluidbehaviour, dispersion modelling, and the systems and procedures in place to mitigatethe consequences should an accidental release occur. To properly assess the hazard

from HVP product and construct an effective ERP requires appropriate expertise from arange of disciplines. Companies should ensure that persons undertaking a hazardassessment for HVP product are competent and suitably qualified by virtue of theirtraining and experience.

The primary hazard associated with HVP products is direct exposure to flame. Uponrelease, immediate ignition could occur resulting in a jet fire, or a dense gas cloud couldtravel to a delayed ignition source, resulting in a flash fire or an explosion. The largesthazard area for emergency response planning is the flash fire. Companies shouldconduct adense gas plume dispersion assessment for each facility to determine the sizeof the EPZ.

For HVP product pipelines the drained volume is the sum of release volumes that existbetween emergency shutdown valves (ESD) valves and check valves. The EPZ for aHVP production facility is calculated from the largest HVP product release volumefrom any pipeline entering or leaving the facility.

Mitigation actions should be accounted for in the EPZ calculation, but they have to bepractical and explained in the documentation supporting the ERP so that the ERCB canbe satisfied that they are appropriate.

3.3.1 HVP Product Release Rates Pipelines

For a pipeline, the mass release rate profile from a guillotine break is calculated usingthe maximum licensed pressure:

The calculation assumes that the ESDs close instantaneously.

1 The table in Appendix 10 is from a report to the HVP Working Group on The Effects of HVP System Parameters onDispersion and Thermal Radiation Hazard Extents by Jacques Whitford AXYS Ltd.


32/103


Initially a liquid stream will be released until the exit pressure drops to the vapourpressure. This occurs very rapidly and can be ignored in the modelling.

Following the liquid stream there will be a steady two-phase flow that will continueuntil the pressure drops below the vapour pressure. This portion of the releaserequires modelling as it is where the majority of the material is released.

The final portion of the release is a vapour and can be ignored in the modellingsince it will not contribute significantly to the hazard distance.

3.3.2 HVP Product Release Rates - Cavern Storage Facility

For a storage cavern the release is modelled as a continuous release until the cavern isdepleted, or the release is modified by a mitigation action such as ignition.

3.3.3 Gas Composition

HVP product facilities may handle batches of product with distinct compositions. Therepresentative composition of each HVP product batch mixture should be modelled.The EPZ is determined by the batch with the largest hazard area.

3.3.4 Depressurization to Atmospheric Pressure

During a release, HVP product exiting as a two-phase flow expands rapidly to

atmospheric pressure. The temperature of the fluid will drop further and additionalliquids will form:

Real fluid behaviour and the presence of liquid aerosol should be accounted for inthe dense gas dispersion modelling because it can have a significant effect on initialconditions and the downwind concentrations of HVP product.

All of the released material is assumed to enter the cloud as a vapour or an aerosol(i.e., no liquid pool is formed on the ground).

3.3.5 Release Orientation

The most conservative release orientation (i.e., horizontal or vertical) is assumed.Typically the most significant release is a horizontal release.


33/103


3.3.6 Release Duration

Pipelines

The release duration from an HVP product pipeline is determined from the massbetween ESD valves and the steady two-phase flow release rate at the vapour pressure.

Storage Cavern

For a storage cavern the duration is determined by the mitigation action or the time todeplete the cavern of its product. For modelling purposes the minimum ignition delaytime is 15 minutes. This is to ensure a margin of safety within the EPZ calculation.Note that prompt ignition (i.e., sooner than 15 minutes) should be planned for withinthe ERP.

3.3.7 Dispersion Modelling

A dense gas dispersion model designed for source conditions that include condensedliquids as an aerosol should be used to calculate downwind concentrations.

A parallel airflow model is acceptable because releases occur at or near ground leveland the release is dense (i.e., is heavier than air). Local terrain effects that may channelthe release need to be identified and considered in the ERP.

3.3.8 Meteorological Conditions

Dispersion of the HVP product plume is dependent on the meteorological conditionsduring the release. The EPZ is based on the worst case meteorological conditions thatresult in the largest predicted distance. Low wind speed and very stable conditions willusually determine the EPZ.

3.3.9 Averaging Times

The shortest averaging time that the model allows (i.e., typically 10 seconds) is used forthe calculation. This is to account for peak concentrations above the longer term releaseduration average that may be within flammable limits.

3.3.10 Emergency Planning Zone Endpoints

The EPZ represents the distance to the hazard following an accidental release of HVPproduct at which direct exposure to flame could occur. Ignition of a gas/air mixturecan occur only when the ratio of gas-to-air in the mixture falls between the upperflammability limit (UFL) and the lower flammability limit (LFL) of the mixture.Dispersion models calculate LFL as an average value. As the gas to air mixture in the


34/103


atmosphere may fluctuate above and below average values, LFL/2 should be used asthe accepted endpoint.

3.4 Emergency Awareness Zone

The Emergency Awareness Zone (EAZ) is a planning zone surrounding the EPZ wherea response to an emergency may be required if the hazard expands beyond the originalEPZ. Companies should be cognizant of the physical features and characteristics of thearea (roadway systems, key geographic features); however, unlike the EPZ, companiesare only required to identify where the urban density developments, public facilities orpublicly used developments are located and to place them on their ERP map.

3.4.1 EAZ for an H2S Release

The EAZ for an H2S release was previously based on the area from the edge of the EPZ to twicethe radius of the EPZ. It did not appear to have any scientific basis and was more or less a ruleof thumb to define an area that might need response actions if the release extended beyond theEPZ. The edge of the EPZ as defined by ERCBH2S is the distance to the indoor H2Sconcentration of 10 ppm and has real value for an emergency response coordinator in planningpublic protection measures.

1. Will we expect to get distances to the EAZ boundary that are greater then what we had

before? It used to be 2 times the EPZ radius. Most of the calculated EAZ distances to theoutside boundary are about 1.5 times or less than the EPZ radius which results in a smallerdistance then was previously used.

3.4.2 EAZ for an HVP Product ReleaseThe ERCB has not developed a dispersion model for determining the EAZ of a HVPproduct release. For an H2S release, the EAZ as determined by ERCBH2S indicates thatthe distance to the EAZ boundary is approximately 1.5 times the EPZ radius. Untilthere is further development by the ERCB on an HVP dispersion model, the distance tothe EAZ for an HVP product release has been set at this number.

3.5 Initial Isolation Zone

ERCBH2S provides valuable information to emergency responders in identifyingresident locations in proximity to a continuous sour gas release from wells or pipelines(i.e., the IIZ) where sheltering in place will only provide temporary protection forresidents. If the residents could not be safely evacuated and are sheltering, yourcompany will have to consider other public protection measures such as supervisedevacuation or ignition to protect their safety.

If the release from a sour gas or HVP pipeline is from a guillotine rupture, the hazard isa plume of gas, controlled by meteorological conditions and of limited duration.


35/103


Sheltering in place should provide adequate protection for residents as outdoorconcentrations will spike when the plume passes over the residence and declineafterwards.

1. Does the IIZ have to be drawn on the ERP map? The IIZ does not have to bedrawn on the ERP map; however your company should consider ways to retain the

information for use in responding to members of the public that may be in that zoneduring the release of a hazard. That could include listing the information somewhere in

your ERP.

ERCB Intent and Review Instructions for Section 3

The ERCB will review the following when assessing an ERP

Are there surface

developments within the

EPZ?

Cross reference a random number of residencelocations on the map with the confidential residentinformation.

Are there egress issues,dead end roads?

All residents on the dead end roads must be included inthe EPZ and have been included in the publicconsultation.

Is the map EPZ clear

and large enough to

assess secondary roads

and access to the

residences?

Some maps are not to the appropriate scale to be able toevaluate if there are any egress issues or houses closelyadjacent to the EPZ.

Has the H2S release rate

assessment been

conducted in accordance

with Directive 056?

The ERCB strongly encourages the filing of apresubmission H2S release rate assessment to itsGeology and Reserves Group for review prior to the

submission of an application.

Has all required

information been

properly entered into

the ERCBH2S model

spreadsheet?

Conduct a random check and cross reference pipelineinformation with IAR. Review batch page to determineif any information is missing.

Does ERCBH2S indicate

companion planning guide to ercb directive 071

Documents